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0Question
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RyanWhat is the process, if any, for borrowing or temporaily tranfering user days between outfitters?
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You have to buy a portion of a company, which is then reviewed and approved by the RMAC and the Planning Commission
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RyanIs there an annual commercial permit fee? If so, what is it?
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yes: for county = $200/year and $2/person; BLM = $105/yr and $3/person; State Parks = $300/yr and $3/person (*says we should find out if we can get these fees waived for being a 501c3
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BillHow did this proposal arise and has it been considered by the RMAC?
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the situation is an anomoly; two permits "popped up" and Noah came up with this proposal of spreading the days amongs the institutionals. If the institutionals do not accept the proposal, then the two permits would probably be sold to the commercials that may want them. either way, they need to do something with these permits and Noah thought this might be a good opportunity for any institutionals that want to have a commercial permit to get one.
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BillHow does this proposal tie into the Draft Institutional process we spent so much time on?
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If this proposal is accepted by the institutionals, this could potentially eliminate the need to revise the draft institutional process; but if some groups say yes to this proposal and others do not; then they would probably need to continue working on the draft institutional process.
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HaroldDo you understand that the proposal appears to significantly curtail our ability to fulfill our mission?
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--response was dodgey--he made some comments about fundraising and eventually seemed willing to consider that accumulated fees could prevent us from being able to continue our work; but he didn't really have much to say in response to this questions.
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HaroldIf so, would you be open to any discussion of ways to eliminate that negative impact?
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Noah suggested we contact the other entities (blm and state parks) to see about any exemptions to fees; and fundraising. He also stated that under this proposal those groups that accepted the permits could borrow user days from each other which could alleviate our concern about group size on river.
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Mel
How can we negotiate for larger User days? Is it possible that some groups do not need the 19 suggested user numbers and would be willing to give up some of their allocations to larger groups?
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it would be quite possible to negotiate; especially if some groups do not want to participate in this proposal and do not accept the permit bc then the groups that do accept would have more days to divy up amongst themselves.
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MelWhat limitations will we see if/when the carrying capacity of the river reaches the need for reduction Level Three actions?
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his immediate response was "we're not even at level 2 yet" and then added that fees would go up if capacity goes up; we'd see some type of allocation system implemented
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Mel
In 6.2.1.3.6 in Exhibit A, it says User days cannot be transferred, loaned or borrowed. In Noah's email he says we could " partner up to run some of your larger trips". Is he suggesting this part of the plan get changed?
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yes; essentially, Steve from commercial outfitter has asked Noah to consider and propose to RMAC that they make this kind of borrowing or partnering up legal so that this practice (which is already happening) can be made transparent and folks could help each other out.
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MelDoes our participant population fit the extra guide exception noted in 6.2.1.3.4.3 in Exhibit A?
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yes; our guides and trainees would not be part of the count; but the non-paying guests (i.e. a family member) that are not part of the participant group are a part of that count.
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Mel
Will we need to file an application fee ($300 the first year) even if the River Use Permit is given to us to cover adminsitrative costs?
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yes; he says it's 200/year and the county would reissue the permit every 3 years. We would not need to pay this fee in 2015 (if proposal is accepted) but beginning 2016 yes.
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Mel
Exhibit A says they can't give out any more RIVER USE PERMITs, so how can they issue 7 more? Or is it they can't add any more users days to the carrying capacity and splitting user days from 2 RIVER USE PERMITS is fine?
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They can't add any more user days; and splitting user days from 2 river permits is what's he's proposing be ok'ed by the RMAC
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MelWill we be required to hold a valid El Dorado County business license as written in 6.2.9.2?
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technically yes ($32/yr) but we are exempt
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MelWill we need to provide a water notice to all our participants as written in 6.2.9.3?
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yes; it can live in the fine print of our waivers or where ever we want it to.
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MelAre they willing to negotiate user fees?
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Noah would be willing; but it's not up to him he says. The fees have been set by the Board of Supervisors and they haven't changed since 1997
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Margery
How many user days are available to the 7 institutional groups from the retiring commercial permits? How many user days will each group receive? How will these be allocated?
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It's in the table provided in the docs he emailed; but essentially 136 weekend and 100 weekday. Each group would receive 19 weekend and 14 weekday; they would be split evenly among the groups that accepted this proposal (so potentially the user days could be higher if not all groups participate)
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Bill
If we accept this offer will we also be able to operate under the proposed institutional guidelines if/wehen the County implements them?
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No.
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Jeremy
Please enumerate the definitive list of regulation documents that ICO will be expected to follow, including priority in case of conflicts, and reasoning where appropriate.
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he can send us the permit application which lists these regulations out.
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* Some additional notes:
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We don't have to accept this proposal
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Noah is really interested in seeing the institutional group category be eliminated for good (with the exception of some not for profit school/college groups)
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If we don't accept this proposal AND if Noah continues to work on eliminating the insititional group category; we would fall under private boaters
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Regardless of whether we accept this proposal or not, they will continue to work on the draft Institutional process, which will still result in regulated user days and revised group size allowances.
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When asked about ramifications for not reporting on time or other violations, Noah stated that he's pretty flexible with payments and could even com to some agreement with the group around how often we send payments in. Also he said that he cares more about reports being turned in on time, but within a week of the trip occuring is fine; his bigger pet peevs for which he would implement violations are around quiet zones and river conduct. He did make the disclaimer that he cannot speak for his predecessor's willingness to be flexible if/when he's no longer there.
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BillWhy is Noah working to eliminate the Institutional category?
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MargeryWhy not sell the 2 commercial permits to interested Institutional Groups, and leave the remaining groups as Institutional Groups?
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Margery
If the Institutional Group category were eliminated, and ICO did not acquire a commercial permit, would ICO as private boaters need a Special Group permit for each river trip?
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MargeryHow will each group manage their programs with only 19 weekend user days each? That's 3 to 4 boats per weekend.
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MargeryWhat justifies the reduction of user days for Institutional groups if the river is not approaching carrying capacity?
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